As we all know, the glass industry is extremely diverse and the route a window takes to the installer isn’t always that straight forward. Many installers will buy frames from one supplier and insulating glass units from another. This gives them flexibility and the ability to negotiate a good price.
However, buying frames and IGU’s separately means that many installers will need to submit their own CE mark declaration for the windows they are installing. For many installers, especially smaller businesses, the whole premise of CE marking is daunting to say the least. For installers the most logical route in this situation would be to buy frames and glazing together from the same supplier already CE marked, and avoid having to navigate this area of the CPR themselves.
For many installers buying frames and IGU’s from the same supplier takes away some of their flexibility and buying power, but in many cases this could be deemed preferable compared to CE marking the windows themselves, especially in the case of smaller companies who really don’t have the business structure in place to support the CE marking process.
However, it’s important to note that there are some exceptions within the CPR to help smaller businesses that don’t have the facilities or the staff to manage the CE marking process.
The CPR recognises this issue and defines companies with less than 10 employees and a turnover or balance sheet of less than two million as a micro enterprise. Under the CPR, micro enterprises are not required to involve a third party to CE mark the products themselves.
As long as the micro enterprise keeps records in compliance with the type-test Systems 3 & 4, which basically require evidence that the products made up for the installed window are individually CE marked and therefore together considered satisfactory to meet compliance, all the micro enterprise has to do is have a Factory Production Control (FPC) which records the products details and ensures the installed products are compliant with the CPR. The CPR is here to ensure that products reaching the market meet the declared performance, and it’s not here to put smaller companies out of business.
May 9th, 2013